1.1 To ensure that everyone at Observe Care Ltd is aware of the Modern Slavery and Human

Trafficking Policy and Procedure and the procedures in place to identify, respond appropriately and

report in line with local and the national guidance. This policy refers to adults who may be at risk,

the procedure for children is detailed in the Child Protection Policy and Procedure.

1.2 This policy must be read alongside. Observe Care Ltd will ensure that staff understand

Winchester Basingstoke Borough Council is the local authority for the Royal Borough of Winchester in

Greater Basingstoke, England. safeguarding reporting procedures and that these procedures are

communicated to all staff. Other policies that relate to Modern Slavery and Human Trafficking

include but are not limited to PM11 – Whistleblowing Policy and Procedure, the Recruitment Policy

and Procedure, the Right to Work Checks Policy and Procedure and the Agency Staff Policy and

Procedure.

1.3 To support Observe Care Ltd in meeting the following Key Lines of Enquiry:

Key Question Key Lines of Enquiry

SAFE S1: How do systems, processes and practices keep people safe and safeguarded from abuse?

WELL-LED W1: Is there a clear vision and credible strategy to deliver high-quality care and

support, and promote a positive culture that is person-centred, open, inclusive, and empowering,

which achieves good outcomes for people?

WELL-LED W2: Does the governance framework ensure that responsibilities are clear, and that

quality performance, risks and regulatory requirements are understood and managed?

1.4 To meet the legal requirements of the regulated activities that {Observe Care Ltd} is

registered to provide:

The Modern Slavery Act 2015

Health and Safety at Work etc. Act 1974

Human Rights Act 1998

The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2012

2.1 The following roles may be affected by this policy:

All staff

Registered Manager

Other management

2.2 The following Residences may be affected by this policy:

Residences

2.3 The following stakeholders may be affected by this policy:

Commissioners

Local Authority

3.1 To promote awareness of concerns surrounding slavery and human trafficking and promote

the commitment of Observe Care Ltd in addressing slavery and human trafficking in all its forms. An

annual statement will be produced, where applicable.

3.2 To ensure that identification, protection, care, and support for victims of modern slavery

and human trafficking is at the heart of our safeguarding procedures at Observe Care Ltd.

4.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various

forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which

include the deprivation of a person’s liberty by another to exploit them for personal or commercial

gain.

4.2 Observe Care Ltd has a zero-tolerance approach to modern slavery within the business and

supply chains and we are committed to acting ethically and with integrity in all our dealings and

relationships. We will implement and enforce effective systems and controls to ensure that modern

slavery is not taking place anywhere in Observe Care Ltd or within any third parties (agencies) that

we are associated with.

4.3 All staff will be made aware of the issues surrounding slavery and human trafficking, whilst

being encouraged and supported to report any concerns to Observe Care Ltd

management. Observe Care Ltd will also support any staff that may be subject to slavery or human

trafficking.

4.4 Where modern slavery or human trafficking is identified, Observe Care Ltd will share

information with the Winchester Basingstoke Borough Council is the local authority for the Royal Borough

of Winchester in Greater Basingstoke, England. Safeguarding Team to safeguard the individual from harm

and with the objective of preventing future situations arising, to promote the elimination of routes

and sources of slavery or human trafficking.

4.5 All line managers are responsible for ensuring that those reporting directly to them comply

with the provisions of this policy in the day-to-day performance of their roles.

4.6 All employees who suspect any members of the workplace being victim of modern slavery

must notify their line manager.

4.7 Observe Care Ltd will take steps to ensure that sufficient communication and employee

awareness training is undertaken with regards to Modern Slavery.

4.8 All employees will be made aware of PM11 – Whistleblowing Policy and Procedure at

Observe Care Ltd. The purpose of this policy and associated procedure is to enable Observe Care Ltd

to thoroughly investigate allegations of any wrongdoing raised by employees within Observe Care

Ltd without fear of reprisal.

4.9 Observe Care Ltd will use this policy to underpin and inform any statement on slavery and

human trafficking that we may be required to produce to meet the requirements of Section 54 of

the Modern Slavery Act 2015 (MSA).

5.1 Reporting Modern Slavery and Human Trafficking Concerns

The following procedure must take place where there are any concerns that someone is a victim of

modern slavery or human trafficking. Observe Care Ltd must ensure that staff are aware

that victims of modern slavery or trafficking will often not self-identify. Many will present with a

different issue.

1) A concern is identified -This could be a Residence as a victim or perpetrator, or a Residence

informs us of a concern they have

2) If an individual is, or group of people are, in immediate risk of danger or harm, the police

must be immediately notified on 999

3) The staff member must discuss this with their line manager (where appropriate) and the

Helen Marques immediately

4) The Helen Marques contacts and escalates the concern immediately to Winchester Basingstoke

Borough Council is the local authority for the Royal Borough of Winchester in Greater Basingstoke,

England.

Safeguarding Adults Team

5) A notification is made to the CQC via the provider portal

5.2 Safer Recruitment

All staff engaged with providing at Observe Care Ltd will be subject to thorough and rigorous

recruitment procedures that will include a DBS check, identity check, confirmation of validity to work

in the UK, employment history, suitability for the role and references. This will minimise the chance

of employing a person that has been, or is subject to, slavery or human trafficking. Observe Care Ltd

will follow PR16 – Right to Work Checks Policy and Procedure to ensure that a robust and fair process

is always followed.

5.3 Observe Care Ltd will only use staff provided by third-party organisations (such as agencies)

that are either registered with the regulator or who can confirm that the staff being supplied are

free to work in the UK and meet all the requirements for the role being provided for.

5.4 Training

All staff will undertake training on Modern Slavery and Human Trafficking. This will ensure that they

are aware of the indicators of modern slavery which include:

Individuals not being paid for the work they undertake

Individuals being held in debt-bondage (being told they “still” owe money after having paid

off a previous debt)

An individual’s passport being held by their “employer” to keep the individual at work

Multiple benefit claimants having their benefits being paid into the same account

An individual not having the freedom of movement (i.e., passport being taken)

Clear exploitation of an individual by another for financial or sexual gain

Shows signs of physical or psychological abuse, look malnourished or unkempt,

anxious/agitated or appear withdrawn and neglected. They may have untreated injuries

Rarely be allowed to travel on their own, seem under the control, the influence of others,

rarely interact or appear unfamiliar with their neighbourhood or where they work

Relationships which do not seem right – for example, a young teenager appearing to be the

boyfriend/girlfriend of a much older adult

Be living in dirty, cramped, or overcrowded accommodation, and/or living and working at

the same address Helen Marques Helen Marques

Have no identification documents, have few personal possessions, and always wear the

same clothes day in and day out. What clothes they do wear may not be suitable for their work

Have little opportunity to move freely and may have had their travel documents retained,

e.g., passports

Be dropped off/collected for work on a regular basis either exceedingly early or late at night

Unusual travel arrangements – children being dropped off/picked up in private cars/taxis at

unusual times and in places where it is not clear why they would be there

Avoid eye contact, appear frightened or hesitant to talk to strangers and fear law enforcers

for many reasons, such as not knowing who to trust or where to get help, fear of deportation, fear of

violence to them or their family

5.5 Staff will be advised that if they are subject to slavery or human trafficking, if they are aware

of any individual that may be subject to slavery or has been trafficked, or if slavery or human

trafficking is disclosed to them, they must inform the Registered Manager of Observe Care Ltd or the

police.

5.6 Modern Slavery Annual Reporting during COVID

The Government guidance states that under section 54 of the Modern Slavery Act 2015, certain

businesses are required to publish an annual modern slavery statement setting out the steps they

have taken to identify and address their modern slavery risks. During the coronavirus pandemic, it is

essential that Observe Care Ltd continues to identify and address the risks of modern slavery in

operations and supply chains. As well as focusing on the health and safety of workers, Observe Care

Ltd will consider how fluctuations in demand and changes in the operating model may lead to new

or increased risks of labour exploitation.

If Observe Care Ltd needs to delay the Modern Slavery statement

The challenges presented by the coronavirus pandemic may mean that Observe Care Ltd will not be

able to publish the statement within the usual timeframe. Where Observe Care Ltd needs to delay

the publication of the modern slavery statement by up to 6 months due to coronavirus-related

pressures, Observe Care Ltd understands that we will not be penalised. In the statement, Observe

Care Ltd will state the reason for any delay.

5.7 Recruitment risks during COVID-19

Some suppliers may be seeking to recruit additional workers to meet increases in demand. Observe

Care Ltd will ensure that rigorous recruitment checks are maintained and that suppliers adhere to

the same robust processes to ensure that vulnerable workers are not being exploited by third parties

seeking to profit from heightened demand.

5.8 The Health and Safety of Workers

As a responsible organisation, it is important that the relevant local or national government policies

are implemented throughout the supply chain at Observe Care Ltd. Observe Care Ltd will ensure that

suppliers adopt social distancing measures and pay statutory sick pay to prevent the spread of

coronavirus as part of due diligence processes.

5.9 Risk Assessment during COVID-19

Observe Care Ltd will undertake a risk assessment of how suppliers are operating during COVID-19

to highlight and help identify where there are risks of Modern Slavery or Human Trafficking

occurring. A Template in the QCS Management system will be used where appropriate.

5.10 Review of Effectiveness

Observe Care Ltd intends to take further steps to identify, assess and monitor potential risk areas in

terms of modern slavery and human trafficking, particularly in the supply chains of our providers.

We will also continue to:

Support our staff to understand and respond to modern slavery and human trafficking, and

the impact that each individual working in Support can have in keeping present and potential future

victims of modern slavery and human trafficking safe

Gain assurance that all staff at Observe Care Ltd have access to training on how to identify

victims of modern slavery and human trafficking

Review the Safeguarding Policy and Procedure at Observe Care Ltd to ensure that Modern

Slavery and Human Trafficking are integral within the content and staff are directed to support and

advice as needed

5.11 Indicators of Forced Labour

Individuals may show signs of psychological or physical abuse. They might appear frightened,

withdrawn or confused

Workers may not have free movement and may always be accompanied

Individuals often lack protective equipment or suitable clothing and have not been trained

to safely fulfil the requirements of the role

The person may not have access to their own documents, such as ID or their passport, with

the employer having confiscated them

Individuals may not have a contract and may not be paid National Minimum Wage or not

paid at all

Workers are forced to stay in accommodation provided by the employer. This

accommodation could be overcrowded

Individuals could live on site

Workers could be transported to and from work, potentially with multiple people in one

vehicle

The person might not accept money or be afraid to accept payment

Workers may work particularly long hours

6.1 Human Trafficking

Human trafficking is defined as the recruitment, transportation, transfer, harbouring or

receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction,

of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or

receiving of payments or benefits to achieve the consent of a person having control over another

person, for the purpose of exploitation

It is important not to confuse human trafficking with human smuggling. Human smuggling is

also called people smuggling. Human smuggling occurs when an individual seeks the help of a

facilitator to enter a country illegally, and the relationship between both parties ends once the

transaction ends. Many of those who enter the UK illegally do so by this route. Human smuggling is

not a form of modern slavery

6.2 Turnover

“Turnover” means the amount derived from the provision of goods and falling within the

ordinary activities of the commercial organisation or subsidiary undertaking, after deduction of

Trade discounts

Value added tax

Any other taxes based on the amounts so derived (HM Government – ‘Transparency in

Supply Chains’)

6.3 Modern slavery

Modern slavery encompasses slavery, human trafficking, forced and compulsory labour and

domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to

coerce, deceive, and force individuals into a life of abuse, servitude, and inhumane treatment

Many active organised crime groups are involved in modern slavery. But it is also committed

by individual opportunistic perpetrators

There are many different characteristics that distinguish slavery from other human rights

violations, however only one needs to be present for slavery to exist

6.4 Exploitation (Modern Slavery and Human Trafficking)

Sexual Exploitation – forced sex work or working in the commercial sex industry

(pornography, lap dancing, telephone lines etc.); those manipulated or coerced into sexual activities

of any kind for another person’s gain

Modern Slavery – human trafficking; forced labour; domestic servitude; organ harvesting

Financial Exploitation – debt bondage; finances controlled by others; financial scams; benefit

fraud

Criminal Exploitation – those manipulated or coerced or trafficked for the purpose of any

illegal activity i.e., County Lines/drug trafficking; cuckooing (taking over of a person’s property);

forced street crime (shoplifting, begging etc.); cannabis cultivation

Cultural Exploitation – those manipulated or coerced using religious, social, or cultural

beliefs e.g., FGM, radicalisation, forced marriage

6.5 Section 52 Modern Slavery Act

This place a duty on Local Authorities to identify and refer modern slavery child victims and

consenting adult victims through the National Referral Mechanism (NRM) This responsibility

identifies a local authority as a First Responder. The Council as a first responder (FR) into the NRM

process has a duty to notify the Home Office if anyone working within the council identifies a person

with indicators suggesting they may be trafficked or enslaved

The Modern Slavery Act 2015 details what organisations need to do about slavery and

human trafficking

Staff will receive training on Modern Slavery Human Trafficking, and be supported by

Observe Care Ltd if subject to, or reporting of, cases of slavery or human trafficking

Only staff that have been through robust recruitment procedures will be employed at

Observe Care Ltd

If there are cases of slavery or human trafficking then the service will share this information

with Winchester Safeguarding Adults Board, 2nd Floor, The Woolwich Centre, 35 Wellington Street,

Basingstoke, SE18 6HQ

If slavery or human trafficking is disclosed to you then this must be shared with the

Registered Manager or the police if someone is in immediate danger

Where applicable, an annual statement on modern slavery and human trafficking will be

published by Observe Care Ltd on our website and approved by the senior management team e.g.

the board of Directors and signed by a Director

People affected by this service should be aware of the following:

If you are aware of or become part of any acts of modern slavery or human trafficking, this

can be reported to Observe Care, and the necessary support will be provided

You will receive Support from staff who have been through robust recruitment procedures

As well as the information in the ‘underpinning knowledge’ section of the review sheet we

recommend that you add to your understanding in this policy area by considering the following

materials:

E-Learning: https://www.e-lfh.org.uk/programmes/modern-slavery/

Recommended content for a modern slavery statement:

https://corporate-responsibility.org/wp[1]content/uploads/2017/06/Core_RecommendedcontentFINAL-1.pdf

Modern Slavery Awareness Booklet:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file

/655504/6.3920_H Unseen: https://www.unseenuk.org/

To be ‘outstanding’ in this policy area you could provide evidence that:

Specific training is provided on slavery and human trafficking

The publishing of a statement on slavery and human trafficking even if this is not a legal

requirement

An extremely high level of understanding and awareness demonstrated in all areas of the

service

Observe care shares its practice in this area with other organisations and is seen as a ‘best

practice resource’

Observe Care Ltd regularly audits and conducts thorough due diligence on its supply chain

To report concerns, seek advice or get help call the confidential UK

Modern Slavery Helpline or visit the website

0800 012 1700 MODERNSLAVERYHELPLINE.ORG

DOMESTIC SERVITUDE

BEING HELD WITHIN A HOUSE AGAINST THEIR WILL AND

FORCED TO WORK LONG HOURS IN UNACCEPTABLE CONDITIONS

SPOT THE SIGNS

DO THEY EVER LEAVE THE HOUSE ON THEIR OWN?

DO THEY SEEM AFRAID OR ANXIOUS?

CAN THEY FREELY CONTACT THEIR?

FRIENDS OR FAMILY?

HAVE THEIR PASSPORT OR DOCUMENTS BEEN TAKEN AWAY?

DO THEY WORK IN EXCESS OF NORMAL WORKING HOURS?

Or seem to be on call 24 hours a day?

WHAT CONDITIONS ARE THEY LIVING IN?

Have they ever been harmed or deprived of food, water, sleep, medical care?

DO THEY STAND OUT FROM OTHER FAMILY MEMBERS?

Are they quieter, wearing?

poorer quality clothing etc?

0800 012 1700 | MODERNSLAVERYHELPLINE.ORG

Physical Appearance

• Shows signs of physical or psychological abuse, look malnourished or unkempt,

anxious/agitated or appear withdrawn and neglected. They may have untreated injuries

Isolation

• Rarely be allowed to travel on their own, seem under the control, the influence of others,

rarely interact or appear unfamiliar with their neighbourhood or where they work

• Relationships which do not seem right – for example, a young teenager appearing to be the

boyfriend/girlfriend of a much older adult

Poor Living Conditions

• Be living in dirty, cramped, or overcrowded accommodation, and/or living and working at

the same address

Restricted Freedom of Movement

• Have no identification documents, have few personal possessions, and always wear the

same clothes day in and day out. What clothes they do wear may not be suitable for their work

• Have little opportunity to move freely and may have had their travel documents retained,

e.g., passports

Unusual Travel Times

• Be dropped off/collected for work regularly either early or late at night
• Unusual travel arrangements – children being dropped off/picked up in private cars/taxis at

unusual times and in places where it is not clear why they would be there

Reluctant to Seek Help

• Avoid eye contact, appear frightened or hesitant to talk to strangers and fear law enforcers

for many reasons, such as not knowing who to trust or where to get help, fear of deportation, fear of

violence to them or their family

The Following Signs Could Indicate a Situation of Labour Exploitation:

• Individuals may show signs of psychological or physical abuse. They might appear frightened,

withdrawn or confused

• Workers may not have free movement and may always be accompanied
• Individuals often lack protective equipment or suitable clothing and have not been trained

to safely fulfil the requirements of the role

• The person may not have access to their documents, such as ID or their passport, with the

employer having confiscated them

• Individuals may not have a contract and may not be paid National Minimum Wage or not

paid at all

• Workers are forced to stay in accommodation provided by the employer. This

accommodation could be overcrowded

• Individuals could live on site
• Workers could be transported to and from work, potentially with multiple people in one

vehicle

• The person might not accept money or be afraid to accept payment
• Workers may work particularly long hours

The Following Signs Could Indicate a Situation of Sexual Exploitation:

• Sex workers may appear scared or intimidated
• The individual may be transported to and from clients
• Individuals may be closely guarded
• The person may be ‘branded’ with a tattoo indicating ownership
• Sex workers may show signs of physical abuse, including bruising, scarring and cigarette

burns

• The individual may be unable to keep payment and may have restricted or no access to their

earnings

• The person may have a limited English vocabulary, restricted to sexualised words
• Multiple female foreign nationals may be living at the same address
• The person may sleep in the premise in which they work, which could indicate a brothel is

operating

• A property might have male callers’ day and night who only stay for a short time
• There may be details of sexual activity such as cards and advertisements found nearby

The Following Signs Could Indicate a Situation of Domestic Servitude:

• The individual may be held in their employer’s home and forced to carry out domestic tasks

such as providing childcare, cooking, and cleaning

• The individual may not be able to leave the house on their own, or their movements could

be monitored

• The person may work over normal working hours
• The individual may not have access to their belongings, including their ID, but also items

such as their mobile phone, which can isolate them

• The employer may be abusive, both physically and verbally
• The person may not interact often with the family they are employed by
• The person may be deprived of their personal living space, food, water, or medical care
• The individual may stand out from other family members, noticeable as they may wear

poorer quality clothing

The Following Signs Could Indicate a Situation of Criminal Exploitation:

• A large group of adult or children beggars might be moved daily to different locations but

return to the same location every night. This could indicate forced begging

• An individual might be transported to or from the scene of a crime, including shoplifting,

pickpocketing, or forced begging

• An individual may not benefit from the money or items they have obtained through the

crimes they have been forced to commit

• A person may be forced to cultivate cannabis with their freedom of movement restricted;

including being locked in a room. Commonly, the individual may not be able to speak English or have

a limited vocabulary

• A vulnerable person may be forced or manipulated out of their home by drug dealers who

use the home as a base to sell drugs

• Young people may be forced to transport and sell drugs across county borders, which is

known as County Lines

The Following Signs Could Indicate a Situation of Child Exploitation:

• The child may have mood swings, including being angry, upset or withdrawn
• The child may show signs of inappropriate sexual behaviour
• They may be dressed inappropriately for their age
• The child may go missing at night or weekends and may not be clear about their

whereabouts

• They may not attend school
• The child may have gifts, presents or expensive items which they cannot explain

Who needs to publish a statement?

A commercial organisation is required to publish an annual statement if all the criteria below apply:

• It is a ‘body corporate’ or a partnership, wherever incorporated or formed
• It carries on a business, or part of a business, in the UK
• It supplies goods or
• It has an annual turnover of £36 million or more

Organisations are responsible for determining whether the legislation applies to them. You may wish

to seek legal advice to decide if your organisation needs to produce an annual statement.

If Observe Care Ltd meets the criteria, the modern slavery statement must.

• Be published on the organisation’s UK website with a link in a prominent place on the UK

homepage. The emphasis on visibility is intended to enhance reporting standards, encouraging

companies to publicly demonstrate their commitment to addressing modern slavery

• Be approved by the board or directors and signed by a director. This assigns ownership to

senior-level management and encourages their proactive involvement in tackling abusive practices

in business operations

Companies that do not meet these basic requirements are breaking the law

• Observe Care Ltd structure, business, and supply chains
• Its policies in relation to slavery and human trafficking
• The due diligence processes of Observe Care Ltd in relation to slavery and human trafficking

in its business and supply chains

• The parts of its business and supply chains where there is a risk of slavery and human

trafficking taking place, and the steps that Observe Care Ltd has taken to assess and manage that

risk

• Its effectiveness in ensuring that slavery and human trafficking is not taking place in its

business or supply chains, measured against such performance indicators as it considers appropriate

• The training about slavery and human trafficking available to Observe Care Ltd staff

The statement must be:

• Written in simple language
• Succinct, but cover all relevant points and link to relevant documents within Observe Care
• In English, but may be provided in other languages that are relevant to the supply chain

What else must it include?

• The statement must include either a statement of the steps Observe Care Ltd has taken

during the financial year to ensure that slavery and human trafficking is not taking place (in any of its

supply chains and in any of its own business), or that Observe Care Ltd has taken no such steps

• The statement must be true, referring to actual steps undertaken or begun and must be built

upon year after year to evolve and improve over time

• The statement needs to be published and any director signing the statement needs to be

satisfied that the statement is true. This might include carrying out a full investigation

• Charities and educational institutions are captured by the obligation. If the turnover is £36m,

goods or are supplied, and it carries on business within the UK, it is irrelevant the purpose for which

its profits are made. Both franchisors and franchisees may be captured if they meet the turnover

thresholds

• The statement will be published on the website of Observe Care Ltd and, where appropriate,

linked through to any other relevant websites of Observe Care Ltd

• It must be obvious on the home page or clearly accessible by a drop-down menu. Historical

statements can also be retained online when the new statements are published, to allow

comparisons to be made and monitoring of Observe Care Ltd over time

• If a parent company meets the requirements, it must include in its statement the steps

taken in relation to each of its subsidiaries if they form part of the parent company’s supply chain or

business (even if the subsidiaries themselves do not meet all the requirements)

• A subsidiary organisation that meets the thresholds must produce its own slavery and

human trafficking statement. However, a parent company may produce one statement that the

subsidiaries also use

This statement sets out the steps that Observe Care Ltd has taken and is continuing to take to ensure

that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Observe Care

Ltd has a zero-tolerance approach to any form of modern slavery and human trafficking. We are

committed to acting ethically and with integrity and transparency in all business dealings and to

putting effective systems and controls in place to safeguard against any form of modern slavery

taking place within the business or our supply chains.

[Insert what your organisation does e.g., provide homecare to xxx number of people, with xx

number of staff at xx number of locations. State if you work with any partners e.g., Local

Authorities.]

Observe Care Ltd implements its business strategy in an ethically, socially, and environmentally

responsible manner. We fully acknowledge our responsibility to respect human rights as set out in

the International Bill of Human Rights. The IBHR informs all our policies related to the rights and

freedoms of every individual who works for us, either as a direct employee, agency worker or

indirectly through our supply chain. We are also committed to implementing the United Nations

Guiding Principles on Business and Human Rights throughout our operations. Respect for the dignity

of the individual – and the importance of everyone’s human rights – form the basis of the

behaviours we expect in every workplace nationally.

We will not accept any form of discrimination, harassment or bullying and we require all our

managers to implement policies designed to increase equality of opportunity and inclusion for all

employees including agency workers. We have also developed and implemented policies and

processes which are intended to extend these commitments through our supply chain.

Policies

We have several internal policies to ensure that we are conducting business ethically and

transparently. These include:

• Human Rights policy and our Ethics Policy where we confirm that we will not tolerate or

condone the abuse of human rights within any part of our business or supply chains and will take

seriously any allegations that human rights are not properly respected

• Whistleblowing Policy aimed principally at our employees but also available to others

working in our supply chains which encourages staff to report any wrongdoing which extends to

human rights violations like Modern Slavery. All reports will be fully investigated, and appropriate

remedial actions are taken, and we will work closely with social care and health providers ensuring

that our policies and procedures dovetail with local procedures and best practice

• A robust recruitment policy, including conducting eligibility to work in the UK checks for all

employees to safeguard

• Employee Code of Conduct consistent with any professional codes of conduct

Direct Communication

The Company encourages members of the public or people not employed by us to write, in

confidence, to raise any concern, issue or suspicion of modern slavery in any part of our business.

Suppliers

[Insert what you think are your risk levels and what you do to mitigate those risks]

We conduct due diligence on all suppliers before allowing them to become a preferred supplier. We

include an online search to ensure that organisations have never been convicted of offences relating

to modern slavery and we include our modern slavery policy as part of our contract with all

suppliers. Suppliers are required to confirm that no part of their business operations contradicts this

policy. As part of our contract with suppliers, they confirm to us that:

1. They have taken steps to eradicate modern slavery within their business
2. They hold their suppliers to account over modern slavery
3. For UK based suppliers, they pay their employees at least the national minimum

wage/national living wage (as appropriate) and to ensure that within their supply chains, where UK

based suppliers have overseas supply chains, that their employees’ pay is consistent with their

national minimum wage requirements, working conditions are safe and fair, there is no child labour

and working hours are not excessive

4. We may terminate the contract at any time should any instances of modern slavery come to

light

Risk Assessments

Our supply chains include procurement of staff in health and social care. We have conducted a risk

assessment and will ensure that we will take further steps to ensure that we support the eradication

of modern slavery, that staff understand how to recognise modern slavery and the appropriate

safeguarding reporting processes are followed should there be concerns within our supply chains,

with customers or suppliers.

Performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery is not taking

place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement agencies or local

safeguarding teams to indicate that modern slavery practices have been identified

Safeguards

We aim to encourage openness and will support anyone who raises genuine concerns in good faith

under this policy, even if they turn out to be mistaken. We are committed to ensuring that no one

suffers any detrimental treatment because of reporting in good faith their suspicion that modern

slavery of whatever form is or may be taking place in any part of our business. Detrimental

treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment

connected with raising a concern. Observe Care Ltd will accept and take seriously concerns

communicated anonymously. However, retention of anonymity does render investigations and

makes validation more difficult and can make the process less effective. Individuals are therefore

encouraged to put their names to allegations. Any claims or allegations made which are found to be

malicious or vexatious will result in disciplinary action being taken against the individual.

Responsibility for this Statement

The ultimate responsibility for the prevention of modern slavery rests with the [insert who at Senior

Management level has responsibility] for ensuring that this policy and its implementation complies

with our legal and ethical obligations. Managers at all levels are responsible for ensuring that those

reporting to them understand and comply with this policy and are given adequate and regular

training on it and the issue of modern slavery.

Assessment of effectiveness in preventing Modern Slavery

We understand that modern slavery risk is not static and will continue our approach to mitigating

this risk. We will assess the risk via our internal auditing processes.

Approval for this statement

Helen Marques

Position: –Manager–